CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

This clarification text has been prepared by Nebim Neyir Bilgisayar Sanayii ve Hizmetleri A.Ş. (‘Company’), as the data controller, in order to fulfil the obligation of clarification regarding your personal data processed within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data (‘Law’) and the Communiqué on the Procedures and Principles to be Followed in the Fulfilment of the Obligation to Clarify.

1. Your Personal Data Processed, Purposes and Method of Processing

For Nebim Partner Network (NPN) Nebim Solution Partnership Programme, your personal data will be processed in order to create a Solution Partner Form within the scope of Article 5 of the KVKK, provided that the fundamental rights and freedoms of the data subject are not harmed and based on the provisions that data processing is mandatory for the legitimate interests of the data controller.

Processed personal data;

1. Identification details (name and surname)
2. Contact details (e-mail address and telephone number)
3. Company name
4. Information you add in the Notes section (information about which services and which different functions are requested in these services)

Your personal data (name, surname, e-mail address, telephone number) required for sending commercial messages (name, surname, e-mail address, telephone number) will be processed based on your consent in accordance with Article 6 of the Law on the Regulation of Electronic Commerce and your explicit consent in accordance with KVKK in order to communicate with you, to send commercial messages such as advertisements, campaigns, discounts, promotional notifications about our products and services via e-mail and call.

2. Your Personal Data Collection Method

Your personal data are stored in accordance with the law and good faith, accurately and up-to-date when necessary, for specific, clear and legitimate purposes, in connection with the purpose for which they are processed, in a limited and measured manner, for the necessary periods stipulated in the related legislation or for the purpose for which they are processed and for the necessary periods specified in other legislation. Your personal data is collected from the ‘Become Our Solution Partner Form’ page by filling out the forum over the internet, and the Customer Relationship Management, which processes personal data into the database, is processed automatically by uploading it to the system where the information is collected.

3. Transfer of Your Personal Data

• Your personal data, the establishment or performance of the contract, the necessity of the data controller to fulfil its legal obligation, based on legal reasons, within the scope of the provisions of Law No. 6493 and the relevant legislation and our legal obligations, in order to exercise our legal and administrative rights, to the relevant authorised public / institutional organisations, including but not limited to the BDDK, MASAK, TCMB and, upon request, to judicial authorities or relevant law enforcement authorities,
• Your personal data may be transferred to the program / Business Partner Organizations / Solution Partners that we cooperate with to carry out our software activities,
• Your personal data, within the scope of pre- and post-advertising, pre- and post-launch researches and provided that the explicit consent of the person concerned is obtained for this purpose, to third parties who are our Suppliers who provide services for this business by the Company regarding the services provided on nebim.com.tr (Training, Webinar, Live support, etc.),
• Your personal data, the permissions required to be obtained within the scope of commercial electronic messages sent / to be sent by the company for the marketing of goods and services; to the Message Management System, which is a subsidiary of the Union of Chambers and Commodity Exchanges of Turkey, in order to be stored in a secure environment, to make approval and rejection notifications by recipients, and to exercise the right to complain,
• Your personal data will be shared with the CRM Company for the integration of the permissions required to be obtained within the scope of commercial electronic messages sent / to be sent by the Company for the marketing of goods and services, based on your explicit consent.
• Your personal data will be shared with "TURK Finansal Teknoloji A.Ş. ’, with which we have a business relationship based on the legal reasons that data processing is mandatory for the legitimate interests of the data controller, for the establishment or performance of a contract, it is mandatory for the data controller to fulfil its legal obligation, it is mandatory for the establishment, use or protection of a right, and it is mandatory to process data for the establishment, use or protection of a right.
• Your personal data are transferred to our main shareholder, direct/indirect domestic subsidiaries and shareholders within the scope of our obligations to provide information and similar obligations arising in accordance with the provisions of the relevant legislation, especially the provisions specific to each type of company in the section titled Commercial Companies of the Turkish Commercial Law.

4. Your Right to Apply as a Data Owner

Pursuant to Article 11 of the Law regulating the rights of the person concerned, your personal data;

a) to find out whether it has been processed or not,

b) request information if processed,

c) to learn the purpose of processing and whether it is used in accordance with its purpose,

d) to know the third parties to whom it is transferred domestically / abroad,

d) request correction if incomplete / incorrectly processed,

e) To request deletion / destruction or anonymisation within the framework of the conditions stipulated in Article 7 of the KVKK,

f) to request the third parties to whom it is transferred to be notified of the transactions made pursuant to subparagraphs (d) and (e) above,

g) object to the occurrence of a result to your detriment due to analysis exclusively by automated systems,

ğ) In case you suffer damage due to unlawful processing, you may submit your requests within the scope of the right to demand the compensation of the damage, together with the information identifying your identity, in accordance with the ‘Communiqué on the Procedures and Principles of Application to the Data Controller’, ( Veri Sorumlusuna Başvuru Usul ve Esasları Hakkında Tebliğ ) to Nebim Neyir Bilgisayar Sanayii ve Hizmetleri A.Ş. (‘Company’) with Mersis No. 0630003487100013, Esentepe Mah. Harman 1 Sok. Nida Kule Blok No: 7-9 Interior Door No: 68 Şişli 34394 / Istanbul in writing or by registered e-mail to; nebim@hs03.kep.tr.